cows in field

Who is responsible for the audit trail for transporting milk and hay?

USDA Releases Guidance on handling unpackaged organic products.

The NOP has posted in its Handbook final guidance on whether a hauler of organic bulk products (hay, organic milk) needs to be certified:

NODPA amongst others took an active role in this process with its comments to NOP in response to the draft guidance published in 2012. We stressed that guidance should be both practical, not an unrealistic burden on producers but still maintain the integrity of the product from farm to table. On most levels this guidance does that.

In summary this guidance allocates the responsibility for the audit trail for ensuring that there is no co-mingling of product or contact with prohibited substances when bulk products are transported to whoever pays and controls the trucking. Below is an extract from the guidance that describes what NOP is looking for by way of an audit trail: The certified organic operation responsible for the organic products that are transported must:

  • Maintain records in sufficient detail as to be readily understood and audited;

  • Maintain the audit trail and trace ability of organic products;

  • Prevent comingling and contamination of the certified products during transportation

  • Fully describe the transportation practices in the organic system plan; and

  • Ensure that the transportation records for organic products are available for inspection

With transportation of organic milk the certified organic operation who is responsible for gathering the information for the certifier is the entity that pays for and controls the transportation – the processor; for a producer who is purchasing organic hay then the responsibility shifts to whoever pays for the trucking, so could be either the producer, dealer or farmer selling the hay. NOP is running a workshop for certifiers to ensure that there is consistent interpretation of this guidance.